CODE OF CONDUCT:-

AAK KAMANI PRIVATE LIMITED.

(I) INTRODUCTION:-

AAK KAMANI PRIVATE LIMITED strives through the efforts of its employees to build a reputation of being a trusted Company that conducts its business with integrity and in compliance with the laws and regulations under which we operate.

This Code of Conduct provides guidance for ethical business conduct in a number of areas that KOIPL expects all its employees to adhere to.

(II) DISCRIMINATION:-

It is KOIPL’s policy to afford equal employment opportunity to qualified individuals regardless of their race, color, religion, age, sex, national origin, disability, veteran status or other factors protected by applicable laws, and to provide a work environment free from unlawful discrimination..

(III) CONFLICT OF INTEREST:-

All employees must exercise great care any time their personal interests are in conflict with those of the Company. Although conflicts of interest may arise in many different situations, the general rule always applies: try to avoid situations in which there might be even the appearance that you acted for reasons other than to benefit the Company.

Example: If an employee has a spouse or member of his or her immediate family who is employed by a competitor, supplier or customer of KOIPL, the employee must disclose this fact in writing and must not participate in decisions involving that entity.

(IV) CONCURRENT EMPLOYMENT:-

As employees of the company, we are expected to devote our knowledge, skill and time for the services of the company. To enable us to perform our duties efficiently and to protect the interest of the company we shall not, without the prior permission of the management, engage in simultaneous employment or a position of responsibility (such as a consultant or freelancer) with any other company or take part in any activity that improves or supports a competitor’s position.

(V) PROPRIETARY INFORMATION:-

All data and information, whether electronic, hardcopy or verbal and regardless of whether it is related to internal or external issues shall be handled confidentially. Confidentiality agreements must be signed in advance with third parties if the exchange of proprietary information is unavoidable as part of any negotiation or interaction.

Business information is one of the most invaluable assets of the company. A list of customers, suppliers, channel partners & employees, financial & legal statements, product plans & roadmaps, policy statements & presentations etc. are some examples of such information. Each one of us must strive to maintain its confidentiality and safe guard it from it being misused. By virtue of our employment in a particular department, we may come across certain confidential information, which if revealed to other insiders/outsiders would affect the smooth functioning of the organization. At such instances, we must exercise due diligence and refrain from either letting the information directly or suggesting the same indirectly.

(VI) FAIR COMPETITION:-

KOIPL supports fair and vigorous competition. No confidential information may be exchanged on formulas, prices and pending price changes or customer/supplier relationships in discussions with competition/outsiders.

(VII) COMPLIANCES:-

Safety, quality and efficacy are core considerations for KOIPL, Every stage of the research, development, manufacture, storage and distribution of our products must be conducted in accordance with all relevant applicable internal and external standards, laws and regulations.

(VIII) SAFETY AND ENVIRONMENTAL PROTECTION:-

KOIPL follows all applicable internal and external safety and environmental laws and regulations.

(IX) COMMUNICATIONS AND DISCLOSURES:-

All our communication through whatever channel, must be fair, accurate, timely and appropriately authorized. All employees must be mindful of situations in which they may be perceived to be communicating on the Company’s behalf.

(X) GIFTS AND ENTERTAINMENT:-

Our business decisions are made on merit. No employee should accept gifts from either customers or suppliers if it would put any sense of obligation on the employee to give the customer or supplier more favorable treatment. Any gift of significant value should be reported to the employee’s supervisor.

We will never give or offer, directly or indirectly, anything of value to a customer or government official to influence or reward an action. A business favor, such as a gift, contribution or entertainment, will never be offered under circumstances that might create the appearance of impropriety.

In appropriate circumstances, employees may provide existing or potential customers with reasonable entertainment or gifts. However, the gifts must be permitted by local law, the customer's own policies and KOIPL policies. You should note that all of these standards may change from time to time, so regular inquiry is advisable.

Always present KOIPL and its products, services and capabilities in an accurate and forthright manner.

Treat all customers and suppliers objectively, honestly and fairly.

(XI) HARASSMENT (INCLUDING SEXUAL HARASSMENT):-

KOIPL is committed to providing all employees a work environment free from discriminatory intimidation (harassment). Such harassment can include: verbal or physical conduct by an employee or non-employee which unreasonably disrupts or interferes with another employee’s work performance, and such behavior by employees will not be acceptable.

The following behaviors by employees will not be acceptable.

Harassment based on race, color, gender, national origin, age, and disability can arise through either verbal or physical conduct.

Epithets, slurs, negative stereotyping, or threatening, intimidating or hostile acts, that relate to race, color, religion, gender, national origin, age or disability; and

Written or graphic material that is placed on walls, bulletin boards or elsewhere on the company’s premises, or circulated in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, national origin, age, or disability.

Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature shall be deemed to constitute sexual harassment.

Sexual Harassment is not acceptable.:

NOTE: Should employees have questions, concerns, or reports concerning this subject matter, they should approach the HR department for clarifications/help.

(XII) SUBSTANCE ABUSE:-

KOIPL is committed to establishing and maintaining a safe work environment that is free from the effects of alcohol, drug and other chemical abuse (“substance abuse”)

The manufacture, use, possession, promotion, transfer or sale of unauthorized or illegal drugs or the misuse of any legal drugs, alcohol or other chemical substances on Company premises (including Company parking lots) is prohibited. Similarly, being under the influence of these substances, which could impair judgment, performance or behavior, while on Company premises or while on Company business, is also prohibited.

All employees are required to report to, and remain on, their jobs free from impairment due to substance abuse.

(XIII) DISCIPLINE:-

We appreciate the fact that our employees at times have to work additional hours to complete given assignments. However such delays cannot be routinely compensated by arriving late the next day as this may hinder the smooth functioning of work teams and organization at large. Hence we must report to work well in stipulated time and properly groomed, wearing appropriate and tidy clothing/ uniforms as per the nature of work performed.

(XIV) EMPLOYEE RESPONSIBILITY WITH RESPECT TO STANDARDS AND POLICIES IN THE CODE:-

Violations of, or failure to perform at the standards set forth in, this Code will result in disciplinary actions, up to and including dismissal.

(XV) PROCEDURES FOR REPORTING VIOLATIONS OF THE CODE:-

It is each employee’s personal responsibility to report violations of the KOIPL Code. The preferred method is to discuss any concerns or questions regarding these articles with your HOD or HR Department..

(XVI) Certification:-

I have read and understand the KOIPL Code of Conduct and agree to comply with it. I understand that failure to comply with the Code or to respond truthfully to this Statement of Compliance will be basis for disciplinary action, up to and including dismissal.

(XVII) Except as stated in the Disclosure section below: :-

• I do not know of any interest or business relationship of my family members or mine, which conflicts with the provisions of the Code.

• I do not know of any other activity or set of circumstances that is in violation of the Code.

(XVIII) Disclosure :-

The information provided below discloses circumstance which may be in violation of the Code or possible conflict of interest (including, for me and my family members, the ownership in another business or other business or family relationships which may constitute a “Conflict of Interest,” see page 1 of the Code):